CASP as a Service — Launch Regulated Crypto in the EU Under a MiCA Licence
Reviewed by Oksana Krasilnikova, Head of AML Compliance
Last reviewed:
CASP as a Service (CaaS) allows banks, fintechs, and payment institutions to offer their clients cryptocurrency custody, trading, and fiat deposit/withdrawal services under MiCA authorisation from a licensed crypto-asset service provider — without the need to obtain their own CASP licence, lock up €125,000–€150,000 in regulatory capital, or wait twelve to eighteen months for authorisation. Equilex designs, contracts, and implements the entire system from start to finish. Setup starts at €15,000; typical launch time is about one month.
Setup fee
From €15,000
Time to launch
From 1 month
At a glance
| Item | Detail |
|---|---|
| Model | White-label distribution under a partner CASP's MiCA authorisation |
| Setup fee | From €15,000, depending on scope |
| Time to launch | From 1 month (own authorisation typically takes 12–18 months) |
| Regulatory capital you must post | None — held by the authorised CASP |
| Geographic coverage | EU/EEA markets covered by the partner's MiCA passport |
| Services available | Custody and wallets, exchange, transfers, fiat on/off ramps, virtual IBANs, stablecoin payments |
| Branding | Full white-label — your name, your interface |
What is CASP as a Service?
A crypto-asset service provider (CASP) is a company authorised under the Markets in Crypto-Assets Regulation (MiCA) (opens in a new tab) to provide crypto-asset services in the European Union. CASP as a Service is the crypto equivalent of banking-as-a-service: instead of obtaining your own authorisation, you distribute the services of an already authorised CASP under your own brand and through your own product.
Your clients see your app, your onboarding process, and your pricing. Behind it sits the partner's authorisation, institutional custody arrangements, anti-money-laundering compliance, and regulatory reporting — with Equilex coordinating the legal structure, the compliance framework, and the implementation.
Who is the regulated party?
This is a question that most websites offering services under a third-party brand avoid, and one that every regulator, bank partner, and investor will ask you. An honest answer matters.
MiCA does not provide for a regime of tied agents or distributors comparable to the agency model under PSD2. Under a white-label arrangement, the authorised crypto-asset service provider remains the regulated provider and retains full responsibility towards its national competent authority, including where operational functions are outsourced (Article 73 of MiCA). You own the brand, the interface, and the commercial relationship; the licensed crypto-asset service provider holds the authorisation, the safeguarding obligations for client assets under Article 70, and the reporting obligations.
See also: ESMA's register of authorised crypto-asset service providers (opens in a new tab).
Division of responsibilities
| Function | You | Authorised CASP |
|---|---|---|
| Brand, UX, pricing | Owns | — |
| Customer acquisition | Owns | — |
| KYC / AML execution | Feeds data | Owns |
| Custody of client crypto-assets | — | Owns |
| MiCA reporting to the regulator | — | Owns |
| Regulatory liability for the service | — | Owns |
| Integration and project delivery | Participates | Participates |
| Contracts and compliance documentation | Approves | Approves |
White-label vs buying a CASP vs applying for your own licence
Three routes lead to regulated crypto services in the EU. They differ mainly in speed, cost and how much control you end up holding.
| CASP as a Service (white-label) | Acquiring a licensed CASP entity | Applying for your own MiCA licence | |
|---|---|---|---|
| Time to market | From 1 month | Typically 6+ months, subject to change-of-control approval | Typically 12–18 months; the statutory clock alone is 25 + 40 working days |
| Upfront cost | From €15,000 setup | Six to seven figures for the entity | Frequently €350,000–€900,000 all-in for the first year |
| Regulatory capital | None from you | €50,000–€150,000 plus own-funds requirement | Same |
| Who holds the authorisation | The partner CASP | You | You |
| Operational control | Product and brand | Full | Full |
| EU passporting | Via the partner's passport | Yours | Yours |
| Best for | Testing the market, embedding crypto into an existing product, launching this quarter | Buyers with capital who want the licence immediately | Firms making crypto a core, long-term business line |
Why 2026 changed the calculation
The MiCA provisions on crypto-asset services applied from 30 December 2024, with a transitional period under Article 143 allowing firms operating under national VASP regimes to continue while they sought authorisation. That period ended no later than 1 July 2026, and several Member States shortened it: Germany, Austria and Ireland ended it on 31 December 2025; Lithuania on 1 January 2026; and the Netherlands, Finland, Latvia and Hungary during 2025.
The practical effect is simple. A legacy national VASP registration no longer authorises a firm to provide crypto-asset services to EU clients. A firm operating in the EU market today needs either its own MiCA authorisation or a contractual relationship with an authorised CASP. For most product teams, the second route is the only one that fits a 2026 launch plan.
Deadlines and national transitional rules change. Verify the current position for your target market before you commit — Equilex confirms this in writing during scoping.
Who CASP as a Service is for
- Banks and financial institutions adding digital-asset services to an existing product suite
- Fintechs that need regulated crypto capability without building a compliance function from scratch
- Payment institutions and electronic money institutions extending into digital assets (EU payment institution licence)
- Neobanks and challenger banks embedding crypto under their own brand
- Licensed intermediaries — brokers, wealth platforms, remittance providers — whose clients are asking for crypto
- Firms whose national VASP registration lapsed when the MiCA transitional period ended
What you can offer your customers
| Service | What it means in your product |
|---|---|
| Custody and wallets | Institutional-grade custody and wallet infrastructure for your customers' digital assets, operated under the partner's safeguarding obligations. |
| Crypto trading and transfers | Buy, sell, exchange and move digital assets without the customer leaving your interface. |
| Fiat on/off ramps and virtual IBANs | Movement between euro and crypto, with a dedicated virtual IBAN per customer. |
| Stablecoin and payment integration | Stablecoin rails and payment flows embedded into services you already run. |
| White-label crypto products | Fully branded crypto products launched under your name, not the provider's. |
| Integrated service infrastructure | One coordinated stack covering accounts, transactions, compliance and reporting. |
What is included
Regulatory
- Structuring of the white-label arrangement and the contractual chain
- Verification of the partner's authorisation scope against your intended services
- Assessment of your target markets and of the marketing rules that apply to them
Compliance
- AML/CFT policy, risk assessment and onboarding flows aligned with the partner's framework
- Transaction-monitoring and Travel Rule configuration
- Reporting and record-keeping procedures
Technology and operations
- Technical integration and testing across accounts, transactions and reporting
- White-label configuration and go-live support
- Ongoing operational coordination between you and the licensed provider
Implementation: from scoping to go-live
| Step | What happens | Typical duration |
|---|---|---|
| 01 Scoping | You share required services, target markets, expected volumes, customer profile and regulatory status. | 3–5 days |
| 02 Tailored proposal | Equilex confirms scope, setup fee and the percentage tiers applicable to your volumes. | 3–5 days |
| 03 Service agreement | Commercial terms, billing cycles and service levels are set out and signed. | 1–2 weeks |
| 04 Implementation | Technical integration, compliance setup and onboarding, coordinated across all components. | 2–4 weeks |
| 05 Go live | Your product launches with regulated crypto embedded and operational support in place. | — |
Indicative timings for a standard scope. Complex integrations and additional markets extend the schedule.
Pricing
| Component | Price |
|---|---|
| Setup and onboarding | From €15,000, one-off, depending on scope |
| User onboarding (KYC, liveness) | From €1.00 per user, one-off |
| Ongoing monitoring | From €0.50 per user per year |
| Transaction monitoring (crypto) | From €0.30 per transfer |
| Exchange | 0.20%–0.50% of volume, tiered by monthly turnover |
| Incoming SEPA | Free |
| Outgoing SEPA | From €1.00 per transfer; business volumes 0.25%–0.55% |
| Crypto withdrawals | Fixed fee per asset plus network fee at cost |
Volume discounts apply. Full price list available on request.
Moving to your own MiCA CASP licence later
White-label is a route to market, not a barrier. Many firms launch a product under a partner's authorisation, build volume and customer history over twelve to eighteen months, and then apply for their own CASP licence with a proven track record — which materially strengthens the application. Equilex supports both stages.
Minimum capital requirements under MiCA depend on which services you intend to provide:
| Class | Minimum capital | Services covered |
|---|---|---|
| Class 1 | €50,000 | Reception and transmission of orders, execution, placing, transfers, advice, portfolio management |
| Class 2 | €125,000 | Class 1 services plus custody and administration, and exchange of crypto-assets for funds or other crypto-assets |
| Class 3 | €150,000 | Class 1 and 2 services plus operation of a trading platform |
A CASP must hold own funds equal to the higher of its minimum capital requirement or one quarter of the previous year's fixed overheads. Once authorised, a CASP can passport its services across the EU by notifying its home regulator, which informs the host authorities — services can start shortly afterwards, without a second authorisation.
See also: apply for your own MiCA CASP licence.
Why Equilex
- Lawyers and business specialists, not resellers — the contractual chain and the compliance framework are drafted in-house.
- Licensing work across 19 jurisdictions in crypto, payments, forex and iGaming, including MiCA CASP, Canadian MSB, US MSB, Hong Kong MSO and Georgian VASP.
- Offices in Hong Kong and Warsaw, serving clients across the EU, North America, Asia and Australia.
- One agreement, one project manager, one point of accountability across regulatory, compliance, technical and operational work.
- A documented upgrade path from white-label distribution to your own authorisation.
See also: crypto licensing across 19 jurisdictions and compliance officer support for your Canadian entity.
Frequently asked questions
CASP as a Service is a B2B arrangement in which a bank or fintech offers crypto-asset services to its own customers under the MiCA authorisation of a licensed Crypto-Asset Service Provider, under its own brand, without holding its own licence.
Not necessarily. You need the services to be provided by an entity authorised under MiCA. That can be your own authorised entity, or an authorised CASP whose services you distribute under a white-label agreement.
The authorised CASP. It remains the regulated provider and stays responsible towards its national competent authority, including for outsourced functions (Article 73 MiCA). You are responsible for your brand, your marketing and the obligations set out in the service agreement.
From about one month for a standard scope: roughly one to two weeks for scoping and contracting, then two to four weeks for integration, compliance setup and testing.
Setup starts at €15,000 depending on scope. Running costs are usage-based: from €1.00 per user onboarded, from €0.30 per monitored crypto transaction, and 0.20%–0.50% of exchange volume tiered by monthly turnover.
Buying a licensed entity gives you the authorisation itself but costs six to seven figures and requires change-of-control approval from the regulator. White-label costs a fraction and launches faster, but the licence stays with the partner.
You can operate in the markets covered by the partner's MiCA passport. A CASP authorised in one member state can passport across the EU by notifying its home regulator, which informs the host authorities. Equilex confirms the exact country coverage during scoping.
Typically custody and wallets, exchange between crypto and fiat, crypto transfers, fiat on/off ramps with virtual IBANs, and stablecoin payment flows. The available set depends on the scope of the partner's authorisation.
Yes — virtual IBANs can be issued per customer, enabling euro deposits and withdrawals alongside crypto balances inside your product.
Yes. Operating history and volume built under a white-label arrangement strengthen a subsequent MiCA CASP application. Equilex handles both the white-label build and the later authorisation.
The MiCA transitional period under Article 143 ended on 1 July 2026 at the latest, and earlier in several member states. National VASP registrations no longer authorise crypto-asset services to EU customers.
Check ESMA's public register of authorised CASPs and confirm that the services you intend to distribute fall within the scope of that authorisation. Equilex performs this check and documents it before contracting.
Next step
Share the services you need, your target markets, expected volumes, customer profile and current regulatory status. Equilex will confirm feasibility, name the licensing route and return a scoped commercial proposal.
Ready to get started?
Discuss your license and timeline with our team. We'll get back to you within 24 hours.
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